Cookson v. Ramge, 907 N.W.2d 296

Three Nebraska residents and a nonprofit (Policyholders) sued the Director of the Nebraska Department of Insurance seeking a declaratory judgment about Neb. Rev. Stat. § 44-513.
Policyholders asked the court to declare that § 44-513 bars insurers from charging higher copayments when an insured obtains a covered service from a chiropractor versus a medical doctor, where both are in-network and authorized to perform the service.
The district court denied Policyholders’ summary judgment motion and dismissed the complaint, reasoning § 44-513 does not mandate equal copayments across provider types.
Policyholders appealed directly to the Nebraska Supreme Court, which reviewed statutory interpretation de novo.
The Supreme Court examined the plain text of § 44-513, related statutes in chapter 44 that expressly use “copayment,” and legislative history, and concluded the statute does not require copayment parity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 44-513 requires insurers to impose identical copayments for the same covered service regardless of provider type	Cookson: § 44-513’s phrase “entitled to such partial or total reimbursement” means insureds are entitled to equal copayments when services are covered	Ramge: § 44-513 ensures coverage parity among licensed providers but does not mention or require equal copayments; insurers may set different copayments	Court: Held § 44-513 does not require equal copayments; statute mandates coverage parity, not copayment parity

Doty v. West Gate Bank, 292 Neb. 787 (cited for summary judgment and de novo review principles)
Kerford Limestone Co. v. Nebraska Dept. of Rev., 287 Neb. 653 (cited for principle that courts will not read unexpressed meanings into statutes)
Stewart v. Nebraska Dept. of Rev., 294 Neb. 1010 (cited regarding statutory construction and when legislative history may be consulted)